SuV12/h1

No Change

As a young person from this village, I am relieved to see that there are plans to develop more housing, which will include affordable properties. I am currently out- priced from my own community, and would welcome an opportunity to be able to afford to remain within my 'milltir sgwâr '. Of course this must be done sensitively, but the future of this community will depend on young families being able to afford to buy and live here. We have already lost our post office, village shop, pub - this rural Welsh community will be lost if this continues.

Scrap it-not feasible.

The land is unstable, and boggy. There is poor access and exits. there would be a huge increase of traffic in a 30mph zone. a very rural area with many agricultural vehicles going passed. village infrastructure wouldn’t cope as only three buses a day, school bus full already. no facilities in the village.

Abolish it. Plenty of other fields that would have better access, would be more structurally sound, and wouldn’t affect so many families living around it. But if the council has to put a new estate in Llanpumsaint, a huge cash injection will need to be put in to better the infrastructure.

This would ruin the views and space behind a number of properties that border the field. Most importantly though the access would be on to an extremely narrow (unlined) 30mph road that is heavily used by agricultural traffic. The field itself floods constantly and is a just a huge bog. The village has no infrastructure for this sort of development, there are only 3 buses a day, and no facilities apart from a tiny school and a hairdresser. The school bus to town is full. It’s a completely ludicrous suggestion.

The plan should not go ahead

The access road is unsuitable for traffic to be turning out of a junction. The field is extremely soggy and any drainage proposed would mean the water would run down onto me and my neighbours properties thus creating a big issue for us . I don’t believe that the infrastructure of the village would cope with another 20-30 houses as the roads are not brilliant and this would mean an increase in the traffic levels. We currently enjoy the peace and privacy of this village as do many others and this would be compromised.

* Reduce number of houses in proposed development.
* Move proposed development alongside road frontage or to field with more suitable drainage.
*Increase proportion of houses available as first properties/affordable homes for young people & families.

Unsuitable ground for housing as it is a natural bog-there are better suited parts of the field for development that are closer to the road and therefore would have better access and have less issues with drainage. Current services, such as sewerage, roads that access Llanpumsaint village, and the primary school need further immediate investment in order to have adequate provision for extra housing of that amount.

Select an alternative site and reduce the number of dwellings

I am concerned about the number of houses to be built on the site; the ability of the village sewage system to accommodate the additional dwellings; the road access from the site onto the main road; the visual impact of the dwellings on neighbouring properties; the quality of the land (extremely damp); impact on wildlife through loss of habitat

Remove site from the Plan

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan in relation to the allocation for residential development at land Adj. Gwyn
Villa, Llanpumsaint (LDP Ref. No. SuV12/h1) under the provisions of Policy HOM1. The
proposed allocation has been fully assessed and in considering its context and background
(summarised below) it is considered that its continued inclusion will lead to the Plan failing
the 3 Tests of Soundness for the reasons set out below.

Site Background and Context
The allocation relates to the land shaded brown on the Proposals Map extract below and is
proposed for allocation in the 2nd Deposit LDP for the purposes of 20 residential units.

Plan A
(Extract of Proposals Map for Llanpumsaint and land adj. Gwyn Villa Allocation)

As part of the current consultation process into the 2nd Deposit LDP, the Council have again published a “Site Assessment Table” (2023), which provides details of the Council’s analysis of each received Candidate Site submission and existing allocations within the current adopted LDP. Proposed allocation SuV12/h1 was considered as part of this process and as a result the Council concluded as follows:
“Site to be allocated for residential use with reference SuV12/h1, to reflect the existing allocation.”
It is clear from the above that the Council considers that the site is deliverable for the purposes of 20 houses, although it is not clear on what basis this conclusion has been made. We note that he site has not been the subject of any application for planning permission, and therefore its continued allocation must surely be questioned.

The allocation is greenfield in nature with its topography being generally level. The southern and eastern perimeters of the site are bordered by residential properties while the western and northern perimeters are bordered by mature vegetation, trees and hedgerows as can be seen from the aerial photograph below (outlined in red below).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently unknown, however, the eastern perimeter borders the C1301, that being the main road running through Llanpumsaint (see below).

Photograph 2
(Streetscene of C1301)

There have been no planning applications made relating to the allocation in question to date.
The site makes up par of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation SC19/h3 (as can be seen below).

Plan B
(Extract of current LDP Proposal Map for land Adj. Gwyn Villa (Adopted 2014))

Despite having almost 10 years of support for the principle of residential development at the historic allocation from the Council, not a single housing unit has been delivered to date.

Tests of Soundness
Based on the above information and the guidance documents provided by the Welsh Government and Council itself, it is considered that the inclusion of the adoption of the LDP in its current form with the inclusion of the allocation in question, would result in it failing to meet the requirements of the Tests of Soundness, for the reasons summarised below.

Test 1 – Does the Plan Fit?
The allocation fails the test of soundness as its inability to be delivered is in conflict with Paragraph 4.2.2 of Planning Policy Wales (Edition 11) requirements of national planning policy.

Test 2 – Is the Plan appropriate?
The allocation fails the test of soundness as its inability to be delivered would fail to address key issues set out by the Plan (housing supply). The Council’s decision to allocate the land appears to not have been done so on credible or robust evidence.

Test 3 – Will the Plan deliver?
The allocation fails to test the soundness as the site is clearly unable to deliver any new housing. The Welsh Governments Development Plans Manual (Edition 3) is quite clear with regard to rolling forward allocations and states that allocations “… rolled forward from a previous plan will require careful justification for inclusion in a revised plan, aligning with PPW. There will need to be substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered”. No evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be deliverable and so its continued allocation would lead to the plan being deemed unsound on this basis.

In summary, we object to the inclusion of the allocation in question on the basis of the above and that its inclusion within the Plan would result in the document being ‘unsound’.

We therefore respectfully request that this Representation be given careful examination, and that the allocation be removed to ensure that the document passes all the relevant tests of soundness.

Remove allocation SuV21/h1 from the Plan.

We are instructed by Mr J.T.J. & Mrs C.W. Davies to a make a formal representation to the
“soundness” of the Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/058/003, seeking inclusion of their land for future residential development within the
defined settlement limits of Ferryside within the Replacement Local Development Plan.
The Candidate Site comprises a rectangular-shaped former grazing field set to the
immediate rear of the Parc-y-Ffynnon residential estate, which was completed in 2019.
Provision for future access into the rear field has been left over in two points.
We have noted that approximately half of the Candidate Site is included within the Second
draft settlement limits as Residential Allocation Sec2/h2 capable of accommodating 12
residential units according to the housing schedule listed under Policy HOM1 of the Plan.
However, the eastern half of the field has not been included.
This formal Representation relates solely to the unsuccessful part of the Candidate
Site.

The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why all the site was not selected for inclusion within the
Second draft settlement limits of Ferryside, as contained within the Second Deposit Draft.

We note that the submission successfully passed through all three Assessment Stages,
being Stage 1 (site compatible against the location of future growth presented in the
Preferred Strategy), Stage 2A (Initial Detailed Site Assessment), Stage 2b (Further Detailed Site Assessment) and Stage 3 (Sustainability Appraisal and Habitat Regulation Assessment) of the Council’s site assessment. It therefore crucially was adjudged acceptable in all technical aspects of formal assessment but was only partially rejected at the final selection stage, with reasons for non-inclusion reported as follows: “Part of the site is to be allocated with reference SeC2/h2.”

Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the tests for “soundness,” in that the Plan “is not appropriate,” and “will not deliver,” as defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the Second Deposit draft settlement limits for Ferryside, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Ferryside, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”

Figure 1 – Extract from Second Draft Proposals Map with site edged in red

This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Allocation of only Half of Candidate Site
1.1 The Council have not provided any reasoning whatsoever for the draft allocation of only half the Candidate Site. The new settlement limit, as shown by Google Earth in Figure 2 below, does not follow any defensible boundary, such as a hedgerow, treeline or even dividing fence across the enclosure. Its positioning is therefore physically illogical in the context of adding new housing to this part of Ferryside.

Figure 2 – Google Earth (April 2021) – illustrating the cultivated form of the Candidate Site

1.2 We therefore consider that the Council has adopted this rather inconsistent approach on the basis that it only considers that Ferryside should grow by very minor proportions over the Plan Period to 2033.
However, the village is significant in scale, containing several hundred dwellinghouses, primary school, convenience shops, public houses, education centre and railway station. It also possesses good public bus service connections to Carmarthen and Llanelli, with the X11 service calling en-route to Swansea City Centre. In other words, it is highly sustainable as a place to live, work and also continue to accommodate holidaymakers. The village contains several guest houses, caravan and chalet parks serving the tourist sector.
Candidate Site
Draft Housing Allocation Sec2/h2
1.3 The Representation Site indicative site layout plan is reproduced below as Figure 3.
It illustrates for cul-de-sac form of development with a total of 23 detached and semi-detached dwellinghouses set fronting an internal estate road, which can access the site via two independent access points from the Parc-y-Ffynnon estate. Thus the proposed form of layout and development is complementary in form to adjacent established form of residential layout at Parc-y-Ffynnon, with frontage parking, and traditional rear garden space.
1.4 The draft Allocation for only 12 units indicates that one access would be used, being the western access, and thus it would require amendments to the site layout to ensure all vehicles access and egress through that single access.
1.5 We submit that the Candidate Site encompasses the entire rear, south-eastern boundary of Parc-y-Ffynnon properties and thus complemented that entire development in width and form. The proposed draft allocation in only proposing half that area fails to respect that character, and in commiting to allocate land beyond the previous LDP settlement limits, our clients cannot understand the physical logic in not extending the draft allocation over the entire field. The Candidate Site field exhibits a consistent gradient and form across its entire length, and therefore the excluded eastern half bears no difference in profile and physical form to the western draft allocated half.
1.6 Google Earth provides such graphic evidence that the allocation of the whole field will not pose any detriment to the visual amenities of the locality. The eastern perimeter stands as a tall and proud hedgerow, with mature, tall trees to the rear extent. Coupled with the lower ground being dominated by adjoining modern houses, any viewer from public viewpoints on ground east, west and north of Parc-y-Ffynnon will have no ready appreciation that the Candidate Site is wholly developed as opposed to only half developed as suggested by the Council. There is no public access to land to the south given it is significantly higher in contour level, steep and impassable with dense woodland vegetation. It nevertheless presents a “green blanklet” or backdrop to the modest expansion southwards of Parc-y-Ffynnon.

Figure 3 – Indicative site layout plan of proposed Representation Site

2.0 Overall Housing Supply at Ferryside & Carmarthen Cluster
2.1 The proposals under this Representation merely seek the addition of a further 11
residential units to the overall housing supply of Ferryside, to add to the 12 units
already allocated within the draft Plan. Ferryside is defined as a Tier 2 Service
Centre, and lends to the principal service centre centring upon the Carmarthen
Cluster as defined within the draft LDP.
The Carmarthen Cluster aims to provide an additional 1646 residential units over the
Plan period to 2033, and thus the addition of a larger allocated site at Ferryside of 23,
rather than the current draft of 12 units will not lead to an over-supply of
dwellinghouses within the Cluster. The LDP village classification as a Tier 2 Service
Centre implies that it possesses far more community facilities and public
transport links than a typical Carmarthenshire village. Accordingly, it should be
afforded a reasonable level of future housing growth for the next 10 years.
2.2 Ferryside is quite unique in terms of its positioning and setting being part of the
Carmarthen Cluster. It is placed at the south-eastern extremity of the defined area,
bordering the Llanelli Cluster, and its extremity settlements such as Kidwelly.
Ferryside serves a rural hinderland and is the principal settlement off the eastern
banks of the Towy Estuary, and consequently, there are few other defined settlements in this part of the County which contain specific residential allocations.
2.3 Policy HOM1 provides details of the two allocations in Ferryside as shown below.

Figure 4 – Policy HOM1 Residential Allocations at Ferryside

Only one other site is allocated in Ferryside that relates to 12 residential units at “Caradog Court”. It benefits from an extant planning permission dating from 2011, and has been mostly completed, albeit a range of modest, two-bedroomed linked units form the bulk of the remaining allocation of 12 units as defined in the draft Allocation. That site is “carried over” in allocation from the previous 2008-21 LDP.
2.4 We have therefore examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft in the Carmarthen Cluster. The Cluster extends in geographic area to Bronwydd, Cynwyl Elfed, Peniel, Rhydargaeau, Alltwalis and Llanpumsaint to the north of the town. It stretches south-west to Llansteffan and Llangain, and east along the River Towy to include Nantgaredig, Pontargothi, Llanarthney and Capel Dewi. It extends along the A48 road as far as Llanddarog and Porthyrhyd. Finally, it stretches south-east along the Towy Estuary to include Cwmffrwd and Ferryside and partly along the Gwendraeth Valley to Pontyates. The following allocations are noted for their inactivity and undeliverability over the last 8-9 years.
2.5 West Carmarthen (PrC1/MU1) – 700 UNITS
In Carmarthen, great emphasis within the Draft Plan has been placed upon the continued allocation of a large, proposed housing site at West Carmarthen. The site is allocated for 700 residential units as Site PrC1/MU1.
This allocation forms the bulk of a Residential Allocation carried over from the current LDP (2014-21) where the allocation was for 1100 units.
We have calculated that of that 1100 units only a total of 141 were constructed between the Plan Adoption date of December 2014 and start of this Replacement LDP Plan Period of 2018. Since 2018, a further 90 units have been constructed, and we note from Land Registry records that the last completed unit was sold at Maes Macsen in September 2021 (18 months ago).
Therefore, since adoption of the 2014 LDP, only a total of 231 units have been completed, equating to a build rate over that 7-year period of only 33 units per annum. This build rate is considerably lower than the anticipated and much promised
delivery of 1100 units in the Plan Period of 2014 to 2021, which would have expected an annual build rate of 157 units. An actual return of 33 units per annum equates to only a 21% build rate return on that anticipated for delivery in the 2014-21 Plan.
Only 39 of those units were built in 2017-18 accordingly to the Joint Housing Land Availability Study 2018. The 2019 Study reveals that only a further 5 units were constructed in 2018-19. The August 2019 Study reports that none were under-construction at that time. During 2020 and 2021 when Covid-19 restrictions were at their peak, more units were constructed than at any other time in that LDP plan period, and therefore we would submit at this point in our formal objection that low build rates cannot be held to be reduced as a consequence of Covid-19 restrictions.
It is equally noteworthy that at a time when the housing market was at its most buoyant in 2022, that the only housebuilder with a track record on the site had ceased construction and sold their last completion (September 2021). We submit that this is testament to the weak marketability of the West Carmarthen Site.
Only 231 units out of 1100 units of the Strategic Site have therefore been completed in the 2014-21 LDP period, which equates to only 21% of that allocated total.
The Replacement LDP seeks to delivery 700 units over a Plan Period from 2018 to 2033. The extract from the Proposals Map for Carmarthen reveals that the figure includes for 90 units constructed between 2018 and 2021, leaving a balance of 610 units envisaged in the remainder of the Plan Period to 2033. That would equate to a build rate of 61 units per annum over a 10-year period. Based upon previous build rates at this site, such a predicted build rate can be described as overly optimistic, being nearly double that actually achieved on the site to date.
The West Carmarthen draft allocation includes parcels of residential allocations off the flanks of the A40 that were previously allocated within the Carmarthen District Local Plan (1997), and subsequent Carmarthenshire Unitary Development Plan (2003). No progress was made in bringing the sites at Llysonnen Road and Old St. Clears Road forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty-seven years of Development Plan allocations have elapsed without any signs of delivery of the majority of this site.
Clearly, there is no historic demand for a site of this scale in this part of Carmarthen. More physically challenging sites, such as the Roman Park site in Llangunnor by Redrow Homes, and the Mount Pleasant site, also in Llangunnor, by Lovell Homes have come forward, and been fully completed, long before West Carmarthen. Yet still the Council is prepared to allocate the site once again for hundreds of residential units in a new Development Plan.
2.6 Pibwrlwyd (Site PrC1/MU2) – ALLOCATION OF 247 UNITS
We would also question the allocation of land at Pibwrlwyd in Carmarthen, being partly for a residential development of 247 units on the Parc Pibwrlwyd development. The Council published and subsequently adopted Supplementary Planning Guidance on “Pibwrlwyd” in 2014.
Paragraph 3.2 was quite specific in that “The LDP describes the acceptable uses on the site as follows: “The proposed use for the site is for a business park centred around employment uses (Use Classes B1, B2 and B8), with uses associated with, and ancillary to the existing Coleg Sir Gâr.”
A development brief in the form of SPG has been prepared and adopted. This in setting out appropriate uses under Use Classes B1, B2 and B8 for the employment element of the site also explores other compatible uses. Residential use on this site is not considered appropriate.” (self-emphasis)
The Council has seen fit to re-examine the Development Plan status of this Mixed-Use Site and concluded that residential uses should now be brought forward, with a residential capacity of 247 units. No explanation has been provided within the supporting text to LDP policies to warrant a dramatic departure from the adopted SPG.
The site is completely and physically divorced from established housing at Pensarn and Llangunnor. It is physically separated by foot from local schools, community facilities and play facilities by the A40 / A48 trunk road network, with only a dark and insecure pedestrian underpass linking it to the Pensarn Commercial Area.
New housing at this location would accordingly be quite alien in form to the long-established business and education uses at Pibwrlwyd.
2.7 Land off Parc-y-Delyn (PrC1/h4) – ALLOCATED FOR 17 UNITS
This new allocation suffers from including Tree Preservation Orders imposed upon specimens at the proposed vehicle access onto Parc-y-Delyn. The site also appears covered in rich flora and fauna and could harbour biodiversity interests.
2.8 As referenced at the outset of this Section, there are several satellite settlements about Carmarthen contributing housing allocations to the Cluster Total of 1690 dwellings. However, we have discovered that many allocations have simply and conveniently been “rolled over” from the 2014 adopted LDP, or in some cases even earlier from the 2008 Unitary Development Plan. No explanation, evidence or demonstration of viability or deliverability has been provided within the Site Assessment Table (January 2023) to demonstrate such a widespread practice.
The following sites are examples of such dormant sites:
Cae Camfas, Heol Llanelli, Pontyates (SeC1/h4) – ALLOCATED FOR 8 UNITS
This site in Pontyates was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.9 Gwyn Villa, Llanpumsaint (SuV12/h1) – ALLOCATED FOR 20 UNITS
This site in Llanpumsaint was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.10 Fronheulog, Cynwyl Elfed (SuV1/h1) – ALLOCATED FOR 8 UNITS
This site in Cynwyl Elfed was allocated in 2014 in the Local Development Plan, and also the 2008 UDP, and applications for planning permission have been submitted for only two individual houses in the entire 15 years of the above combined Plan Periods have been commenced.
2.11 We submit that the above draft allocations at West Carmarthen be significantly reduced in scale, and in the case of Pibwrlwyd and above-named satellite allocations be omitted from the Plan and that housing allocation be redistributed to modest Candidate Sites, of up to 20-30 units such as that proposed at Parc-y-Ffynnon. There is clear evidence in the rapid completion of the adjoining Parc-y-Ffynnon development that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.
2.13 In the case of Parc-y-Ffynnon, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Ferryside. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of the Carmarthen Cluster.

CONCLUSION
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of all the Candidate Site.
Our clients have illustrated that their indicative proposals to construct a total of 23 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Ferryside. The locality has numerous examples of modern cul-de-sac development being completed at backland / edge of settlement locations, which in turn, advocates that the form of development proposed at Parc-y-Ffynnon is no different, resulting in it being respectful to the character and setting of the locality. The Council have already acknowledged that a backland site is suitable at this location in Ferryside, our clients merely suggest that it be enlarged to encompass all the level field to a parallel position with the constructed Parc-y-Ffynnon development.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Ferryside realigned to include the whole Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Remove site from Plan

I am very disappointed that we only found out about the plan to build on the field behind my property.
I hope you take it in consideration about our privacy, if they build houses on looking into our property. The loss of value to our property. Also light to our property with houses built behind our bungalow.
The field is a bog. The drainage is horrendous. You must also consider the sewerage!! Will it be able to take more properties!!!
The road into the village can just about cope with the traffic.
I can not believe the owner of the field would consider building more houses in the village. There are many for sale and have been for a long time.
There was an objection on building on that field many years ago. Why reconsider it!!!!
I’m sure if there is a need to build, please look at other fields in the village.

No change to the Plan

Thank you for consulting Welsh Water, we welcome the opportunity to continue to engage in the LDP process and we offer the following representation for your consideration:
Issues Identification We note and welcome the inclusion of issue 23 regarding infrastructure capacity to support development. The availability of our infrastructure capacity is a key element – particularly in rural areas - in ensuring sustainable and viable development sites.
Strategic Objectives The availability or capacity of infrastructure is a key aspect in determining the sustainability of a settlement, therefore we support the inclusion of SO6 and SO14.
Strategic Growth and Spatial Options We note that the Council identifies a growth requirement of 8,822 new homes over the revised LDP period 2018-2033.
Preferred Spatial Option Whilst we are supportive of the hybrid option and are pleased to note that it acknowledges the need for development to be supported by a range of appropriate infrastructure, there will inevitably be certain areas – particularly in the more rural locations of the County – where water or sewerage infrastructure is limited in its availability.
Placemaking, Infrastructure and Cohesive Communities We welcome the sentiment of paragraph 9.43. Where there is insufficient infrastructure capacity and development wishes to connect in advance of our AMP capital investment, planning obligations or a commercial agreement are the most appropriate way in ensuring delivery of necessary supporting infrastructure. We also welcome the inclusion of paragraph 9.47 and further commentary can be found in respect of the policy INF4.
Policies
SG1: Regeneration and Mixed-Use Sites Please see appendix 1 for site allocation comments.
SG2: Reserve Sites We note that the reserve sites will only be released for development if the allocations fail to deliver the required growth, and that the decision to utilise the sites will be made as part of a formal plan review. As such we will be happy to provide comments regarding capacity to accommodate sites in due course.
SG3: Pembrey Peninsula Most of the peninsula is unsewered and does not have a water supply with only elements of the southeast of the peninsula currently served by either. As such, any proposals for development may require significant offsite water mains and sewers to connect to existing networks. Further to this, the Pembrey Wastewater Treatment Works (WwTW) that serves the southeast of the peninsula may require additional capacity to accommodate any further development and developers may need to fund reinforcement works at the WwTW.
HOM1: Housing Allocations Please see appendix 1 for site allocation comments.
SP6: Strategic Sites Given that both sites have extant planning permission we have nothing specific to advise.
EME3: Employment Proposals on Allocated Sites The following provisions are applicable to all individual development plots located within allocated employment sites:
• We will work with your authority to support sustainable economic development however your authority and potential developers should be aware that the obligations of a water and sewerage undertaker extends to ‘domestic’ supplies only. Where an employment allocation results in higher demands of water supply and/or trade effluent discharges we recommend and welcome early consultation with Dwr Cymru Welsh Water.
• The individual plots available for development can represent a substantial area of land for which the potential demands upon our assets are unknown at present. It is essential that we understand these demands to allow us to assess the impact on our assets. It may be necessary for water and/or sewerage hydraulic modelling assessments (HMAs) to be undertaken at the developer’s expense to establish where the proposed development could connect to the existing networks, and to identify any required infrastructure improvements.
• Water mains and/or sewerage infrastructure required for any potential development site can be acquired through the requisition provisions of the Water Industry Act 1991 (as amended).
• Welsh Water always has rights of access to its assets. Where there are water mains and/or sewers crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion of the asset.
• If any development site gives rise to a new discharge (or alters an existing discharge) of trade effluent, directly or indirectly to the public sewerage system, then a Discharge Consent under Section 118 of the Water Industry Act 1991 is required from Welsh Water. Please note that the issuing of a discharge consent is independent of the planning process and a consent may be refused despite planning permission being granted.
SP9: Infrastructure The availability or capacity of infrastructure is key in determining a settlement’s sustainability as such we welcome the provisions of this policy in requiring development to ensure sufficient capacity is available or if not, that suitable arrangements are in place to provide the necessary capacity.
With specific regard to water and sewerage infrastructure, where there is insufficient capacity and where no reinforcement works are programmed within the respective AMP Capital Investment Programme, the requisition provisions can be entered into for water and sewerage network infrastructure. The requisition provisions do not apply to wastewater treatment works (WwTW) and planning obligations, or a commercial agreement, may be necessary.
We welcome the reference in the supporting text to Drainage and Wastewater Management Plans (DWMPs). Welsh Water is embarking on the preparation of developing Drainage and Wastewater Management Plans (DWMP) which Welsh Government may be minded making statutory in due course. Growth information is built into our DWMP and forms an important element of our planning which aims to understand how we will continue to deliver effective sewerage services and manage the proactive development of natural flood management for a growing population in the face of climate change and other challenges.
Critically the DWMP considers the impact of changing population on our assets and the subsequent effect to customers and on the environment. As such we believe that the DWMPs will play a role in delivering a holistic, prioritised approach to the management of our drainage and sewerage network in the years ahead, and will complement other planning documents including LDPs, the NDF, and SDPs. To maximise the potential benefits, we are continuing to work closely with our stakeholders and LPAs in the continued development of our DWMP.
INF1: Planning Obligations Where there is insufficient infrastructure capacity available to accommodate a site and development wishes to connect in advance of any AMP capital investment, planning obligations or a commercial agreement are the most appropriate way in ensuring delivery of necessary supporting infrastructure.
INF4: Llanelli Wastewater Treatment Surface Water Disposal We are supportive of the provisions of this policy and the supporting text; moreover, we are pleased to note that the matter has been given its own specific policy. We have also prepared a consultation response to the Burry Inlet SPG which provides further detail on this matter.
SP10: Gypsy and Traveller Provision - Please see appendix 1 for site allocation comments.

SP12: Placemaking and Sustainable Places We specifically welcome the inclusion of criteria k) in Policy SP12. Disposing of surface water in a sustainable manner ensures that it will not communicate with the public sewerage network, which protects the environment and ensures that there is sufficient capacity in the public sewerage network for foul-only flows from development sites. On the theme of SuDS, we welcome the inclusion of the supporting text at paragraphs 11.273 to 11.275 regarding the recently established SuDS Approval Boards (SABs).
PSD3: Green Infrastructure Network We welcome the provisions of this policy and the supporting text. The integration of SuDS as a Green Infrastructure asset is something that we are particularly supportive of.
SP16: Climate Change We are supportive of the inclusion of SuDS in new development and as such welcome the provisions of criterion b) of this policy.
CCH4: Water Quality and Protection of Water Resources we welcome the requirement in supporting paragraph 11.510 that the necessary infrastructure needs to be in place or will be provided to serve development however we would highlight that in cases where there are no plans in place for infrastructure improvements in our AMP investment programme, developers can pay for the necessary infrastructure themselves through the requisition provisions of the Water Industry Act (WIA) 1991 or via Planning Obligations Agreements under the TCPA 1990. It should be noted that the requisition provision of the WIA 1991 only applies to sewerage network reinforcement works, not to WwTW schemes. Funding to deliver reinforcement works at a WwTW can be delivered via Section 106 of the Town and Country Planning Act 1990.
In relation to improving water quality, we are investing an additional £60m specifically to reduce phosphate in the five failing Special Area of Conservation (SAC) rivers in our operating area. This includes schemes at Lampeter and Llanybydder WwTWs that are due for completion by March 2025. In the next investment period 2025 to 2030 (AMP8) we will target investment with the ambition that none of our WwTWs are the cause of ecological failure. Through our phosphorus investment plan, we will have removed 90% of the phosphorus load from our WwTWs discharging to failing SAC rivers, playing our part in allowing these special rivers to meet their water quality targets and to relieve pressure on development restrictions. We expect to complete this programme of work by 2032. Whilst our investment will remove a significant amount of phosphorus from our sewage, in most cases it will not result in SACs complying with the water quality targets on its own. This is not something that Welsh Water can do on its own and it will take the combined efforts of all the contributing sectors to achieve this.

We will be engaging with our regulators and local planning authorities through the Tywi and Teifi Nutrient Management Boards (NMB) which can provide the governance, strategic direction and local intelligence/decision making needed if we are to be successful in relieving the pressure on planning restrictions and restoring river quality.
With regard to supporting text in paragraph 11.516, there are several locations within the County where we abstract water that is treated prior to entering the public water supply network. As such, we fully support the provisions in the supporting text of this policy in preventing the degradation of water resources.

TRA1: Transport and Highways Infrastructure Improvements There may be locations where proposed developments / routes pass over public sewers and water mains. Under the Water Industry Act 1991 we have rights to always access our apparatus and protection measures in respect of these assets will be required either in the form of an easement width or a possible diversion of the asset. We welcome early engagement once further detail is available.
MR1: Minerals Proposals We welcome the inclusion of criterion e) and k) of this policy.
We hope that the above information will assist you as you continue to progress the LDP2 and would encourage the LPA to continue to liaise with Welsh Water at each stage of the process. In the meantime, should you require any further information please do not hesitate to contact us at Forward.Plans@dwrcymru.com or via telephone on 0800 917 2652.